Villareal vs People

ISSUES:

G.R. 151258

1. Whether or not criminal liability for personal penalties of the accused is extinguished by death

G.R. 154954; 155101;178057 & 178080:

1. Whether the forfeiture of petitioner Dizons right to present evidence constitutes denial of due
process;
2. Whether the CA committed grave abuse of discretion, amounting to lack or excess of jurisdiction
when it dismissed the case against Escalona, Ramos, Saruca, and Adriano for violation of the
right of the accused to speedy trial;
3. Whether the CA committed grave abuse of discretion, amounting to lack or excess of
jurisdiction, when it set aside the finding of conspiracy by the trial court and adjudicated the
liability of each accused according to individual participation;
4. Whether the CA committed grave abuse of discretion when it pronounced Tecson, Ama, Almeda,
and Bantug guilty only of slight physical injuries
5. Whether the existence of animus iniuriandi or malicious intent to injure is proven beyond
reasonable doubt?

HELD:

G.R. 151258

1. YES. The death of the petitioner Villareal extinguished his criminal liability for both personal and
pecuniary penalties, including his civil liability directly arising from delict complained of.
According to Article 9(1) of the Revised Penal Code, the criminal liability of personal penalties
(refers to service of personal or imprisonment penalties) is totally extinguished by death of
convict. In contrast, the criminal liability for pecuniary penalties (refers to fines and costs,
including civil liability predicated to criminal offense complained) is extinguished if the offender
dies prior to final judgment.

Note: If civil liability ia based on a source of obligation other than the delict survives the death of
the accused and is recoverable through a separate civil action.

G.R. 154954; 155101;178057 & 178080:

1. YES. The right of the accused to present evidence is guarantted by no less than the Constitution
itself. Article III, Section 14(2) thereof, provides that in all criminal prosecutions, the accused
shall enjoy the right to be heard by himself and counsel.... This constitutional right includes the
right to present evidence in defense as well as the right to be present and defend oneself in
person at every stage of the proceedings.

Based on the case of Crisostomo v. Sandiganbayan, the waiver must be clear and must be
coupled with an actual intention to relinquish the right. The court is called upon to see to it that
the accused is personally made aware of the consequences of a waiver of the right to present
evidence. It is not enough that the accused is simply warned of the consequences of another
failure to attend succeeding hearings. The court must first explain to the accused personally in
clear terms the exact nature and consequences of a waiver.

The waiver of the right to present evidence in a criminal case involving a grave penalty is not
assumed and taken lightly.

2. YES. The right of the accused to the speedy trial has been enshrined in Section 4(2) and 16,
Article III of the 1987 Constitution. This right requires that there be a trial free from vexatious,
capricious or oppressive delays. The right is deemed violated when the proceeding is attended
with unjustified postponements of trial or when a long period of time is allowed to elapse
without the case being tried and for no cause or justifiable motive. In determining the right of
the accused to speedy trial, courts should do more than a mathematical computation of the
number of postponements of the scheduled hearings of the case. The conduct of both the
prosecution and the defense must be weighed. Also to be considered are factors such as the
length of delay, the assertion or non-assertion of the right and the prejudice wrought upon the
defendant.

Based on the case of Abardo v. Sandiganbayan, the unexplained interval or inactivity of the
Sandiganbayan for close to five years since arraignment o the accused amount to an
unreasonable delay in the disposition of cases a clear violation of the right of the accused to a
speedy disposition of cases.

Applying the said principles, the right to speedy trial was violated for the case of Escalona,
Ramos, Saruca, and Adriano.

3. Whether the CA committed grave abuse of discretion, amounting to lack or excess of

jurisdiction, when it set aside the finding of conspiracy by the trial court and adjudicated the
liability of each accused according to individual participation;

Yes. From the proof that the death of the victim was the cimulative effect of the multiple
injuries he suffered, the only logical conclusion is that the criminal responsibility should redound
to all those who have been proven to have directly participated in the infliction of physical
 injuries on Lenny. The accumulation of of bruising on his body caused him to suffer cardiac
arrest.

The Solicitor General posits that since all of the accused fraternity members conspired to inflict
physical injuries on Lenny Villa and death ensure, all of them should be liable for the crime of
homicide pursuant to Article 4(1) of the Revised Penal Code.

4. Whether the CA committed grave abuse of discretion when it pronounced Tecson, Ama, Almeda,
and Bantug guilty only of slight physical injuries

Yes. The CAs ultimate conclusion that Tecson, Ama, Almeda and Bantug were liable merely for
slight physical injuries grossly contradicts its own findings of facts. According to the court, the
accused were found to have inflicted more than the usual punishment undertaken during such
initiation rites on the person of Villa. It then adopted the NBI medico-legal officers findings that
the antecedent cause of Lenny Villas death was the multiple traumatic injuries he suffered
from the initiation rites. Considering that the CA found that the physical punishment heaped on
Lenny Villa was serious in nature, it was patently erroneous for the court to limit the criminal
liability to slight physical injuries, which is a light felony.

Accordint to Article 4(1) of the Revised Penal Code dictates that the perpetrator shall be liable
for the consequences of an act, even if its results is different from intended.

5. No. The CA in finding the accused Dizon guilty of homicide under Article 249 of the Revised
Penal Code on the basis of the existence of intent to kill is not sustainable. Animus interficendi
cannot and should not be inferred unles there is proff beyond reasonable doubt of such intent.
Thus, none of the fraternity members had the specific intent to kill Lenny Villa. Instead, there
was an intent to inflict physical injuries on Lenny Villa.

The absence of the malicious intent does not automatically mean, however, that the accused
fraternity members are ultimately devoid of criminal liability. The Revised Penal Code also
punishes felonies that are committed by means of fault (culpa). According to Article 3, there is
fault when the wrongful act results from imprudence , negligence, lack of foresight or lack of
skill. Reckless imprudence or negligence consits of a voluntary act done without malice, from
which an immediate personal harm, injury or material damage results by reason of an
inexcusable lack of precaution or advertence on the part of the person committing it.